661 F. App'x 977
11th Cir.2016Background
- Dennis Williams applied for Supplemental Security Income claiming disability from back problems, numbness, and depression; ALJ found him not disabled from Nov. 30, 2010 to Aug. 21, 2012.
- ALJ credited treating physician’s notes (given “great weight”) showing sporadic depression complaints and no long-term depression treatment.
- Two consultative examiners rendered opinions: Dr. Sathyan Iyer (some nonspecific functional impairments) and Dr. David Wilson (one-time exam diagnosing depression and suggesting greater limitations).
- ALJ gave “some weight” to Dr. Iyer’s opinion but gave no weight to Dr. Wilson’s opinion because it was a single evaluation inconsistent with longitudinal records.
- ALJ found Williams’s depression medically determinable but only produced mild functional limitations and was not a severe impairment; RFC incorporated mental limitations accordingly.
- District court affirmed the Commissioner’s denial; Williams appealed raising three issues about medical-opinion weight, severity of depression, and substantial-evidence support for the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ improperly rejected consultative opinions | Williams: ALJ rejected Drs. Iyer and Wilson without good cause and substituted his own view | Commissioner: ALJ adequately explained weight; Iyer consistent with RFC; Wilson inconsistent and based on single exam | Affirmed — ALJ properly weighed Iyer and permissibly gave Wilson no weight |
| Whether ALJ erred in finding depression non-severe | Williams: ALJ misapplied "slight" standard; depression should be severe | Commissioner: Only Wilson supported severity; ALJ could reject it as inconsistent with treating records | Affirmed — depression non-severe; ALJ’s application of standard correct |
| Whether RFC failed to account for mental limitations | Williams: ALJ omitted depression-related limitations from RFC | Commissioner: ALJ incorporated mild mental limitations in RFC based on record | Affirmed — RFC accounted for mild limitations; no additional limits required |
| Whether decision supported by substantial evidence | Williams: Errors in weighing and severity findings undermine substantial-evidence support | Commissioner: No legal error; record supports ALJ’s conclusions | Affirmed — substantial evidence supports denial |
Key Cases Cited
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (standard of review and claimant's burden)
- Sharfarz v. Bowen, 825 F.2d 278 (11th Cir. 1987) (ALJ must state with particularity weight given to medical opinions)
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (five-step sequential evaluation framework)
- McDaniel v. Bowen, 800 F.2d 1026 (11th Cir. 1986) (definition of "non-severe" impairment)